G.R. No. 115180 November 16, 1999
FILIPINO PIPE AND FOUNDRY CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, NATIONAL LABOR UNION — TUCP, and EULOGIO LERUM, respondents.

FACTS

The National Labor Union-TUCP (NLU-TUCP), through its national president Atty. Eulogio Lerum, filed a notice of strike against Filipino Pipe and Foundry Corporation on behalf of its local chapter, the Filipino Pipe Workers Union-NLU (FPWU-NLU). The grounds alleged were union busting and non-implementation of a Collective Bargaining Agreement. A conciliation conference was scheduled, but before it could be held, the FPWU-NLU staged a strike on March 3, 1986. The strike lasted until June 13, 1986, when a return-to-work agreement was reached. The petitioner company subsequently filed a petition to declare the strike illegal and sought damages against the union entities and Atty. Lerum. The Labor Arbiter ruled the strike illegal and held NLU-TUCP liable for substantial damages, absolving Atty. Lerum. The NLRC reversed this decision, dismissing the complaint against NLU-TUCP and Lerum, prompting the company’s petition for certiorari.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in ruling that the NLU-TUCP and its president, Atty. Eulogio Lerum, are not liable for damages arising from the illegal strike staged by the local union chapter.

RULING

The Supreme Court dismissed the petition and affirmed the NLRC decision. The legal logic centers on the principle of agency and the nature of liability for an illegal strike. The Court held that the FPWU-NLU, the local chapter, was the principal actor that staged the strike. The NLU-TUCP, as a national federation, and Atty. Lerum, as its officer, acted merely as agents in assisting the local union by filing the notice of strike. Primary responsibility for the illegal strike and any consequent damages rests with the local union as the principal. The Court emphasized that the act of an agent is the act of the principal. Since the petitioner company had already moved for the dismissal of the complaint against the local union’s officers and members, and recognizing the local union as the bargaining agent since 1981, the cause of action for damages against the principal was extinguished. Consequently, the claim for damages against the agent, NLU-TUCP, and Atty. Lerum could no longer be sustained. The NLRC did not act with grave abuse of discretion in applying these agency principles to absolve the national federation and its officer from liability.